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2012-06-26_REVISION - C1981019
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2012-06-26_REVISION - C1981019
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Last modified
8/24/2016 5:01:56 PM
Creation date
6/27/2012 9:48:46 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1981019
IBM Index Class Name
REVISION
Doc Date
6/26/2012
Doc Name
Response & Comments
From
DRMS
To
Colowyo Coal Company
Type & Sequence
TR95
Email Name
RDZ
DIH
Media Type
D
Archive
No
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there is overwhelming evidence to support the use ofHSG `T" soils for all reclaimed <br />areas, and in fact the use of HSG B actually constitutes a conservative assumption. <br />As discussed below, a strong case can be made for selecting HSG A, although that is <br />not proposed here. Referring to Section 630.0701 of the National Engineering <br />Handbook, each HSG is described, and the final sentence of each soil group <br />description provides a minimum infiltration rate. Specifically for deep soils such as <br />regraded spoils covered with topsoil, <br />Hydrologic Soil Group A has a minimum infiltration rate of 1.42 in/hr, <br />Hydrologic Soil Group B has a minimum infiltration rate of0.57in/hr, <br />Hydrologic Soil Group Chas a minimum infiltration rate of 0.06112/12r, and <br />Hydrologic Soil Group D has an infiltration rate of less than that. <br />Finally, the results presented in the 1981 Striffler and Rhodes study clearly indicate <br />that regardless of the mine location, the infiltration rates observed are well beyond <br />those normally assigned to a HSG C soil. Although Colowyo's data is limited to 6 <br />sites which would have had an undisturbed mapped soil with HSG C, the <br />infiltration rate observed in the field tests was well beyond a Type C soil. In fact it <br />appears more like a HSG A soil. The average measured infiltration rate was 5.5 <br />cm/hr (2.2 inches/hr; Table 10 in Striffler and Rhodes). Figure 2 presents a plot of <br />the average infiltration on all 14 sites in that study. These are described in Tables <br />A -1 through A -14 of the Striffler and Rhodes report. There are 76 field infiltration <br />tests altogether represented on Figure 2. Figure 2 is for illustration purposes only <br />and is not intended to be part of the TR -95 revision. Eleven of the sites are clearly <br />HSG B orA soils. Only two of the sites approach a HSG Csoil. <br />CCC never intended to use Striffler and Rhodes to extrapolate between different <br />mines or different regions, but the results of all of the tests clearly indicate the <br />infiltration rate of reclaimed lands is better represented as HSG A or B. In <br />Colowyo's case, the measured infiltration rates suggest HSG A, with infiltration <br />rates over 2 inches/hr. <br />In the review comment above, it is stated that past studies and studies at other sites <br />do not provide justification for altering curve number values. On the contrary, due <br />to the preponderance of high infiltration rates at all reclaimed sites, the exact <br />opposite is true. <br />• Additional information would provide better rationale for altering the CN values. This <br />could include site specific infiltration tests and/or calibration of existing models using <br />rainfall and runoff data. <br />
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